The Money Laundering Reporting Officer (MLRO) is fully responsible for developing, implementing, and maintaining an effective Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework in accordance with AFSA AML/CFT and Sanctions Rules, the Law of the Republic of Kazakhstan on AML/CFT, and relevant regulatory guidance.
The role aims to prevent money laundering, terrorist financing, and fraud, while ensuring effective engagement with AFSA, the Financial Intelligence Unit (FIU), and other competent authorities.
Key Responsibilities
1. AML/CFT, Fraud, and Sanctions Compliance
- Ensure full compliance with AIFC AML/CFT and Sanctions Rules, the Kazakhstan AML/CFT Law, and all applicable regulations.
- Review the adequacy and effectiveness of AML policies and procedures and recommend improvements.
- Oversee the implementation of AML controls and procedures as established in the company’s internal documentation.
2. Customer Due Diligence (CDD/EDD)
- Collect and verify client identification data before establishing business relationships.
- Conduct Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk clients, complex ownership structures, or when circumstances change.
- Monitor customers for Politically Exposed Persons (PEPs) and Ultimate Beneficial Owners (UBOs) status.
3. Transaction Monitoring
- Monitor transactions to identify suspicious activities or deviations from expected business patterns.
- Apply a risk-based approach in transaction analysis.
- Maintain and enhance automated monitoring systems, where applicable.
4. Suspicious Activity / Transaction Reporting
- Receive internal reports of suspicious activities from employees.
- Prepare and submit Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU) through AFSA, in line with AIFC AML Rules and the Kazakhstan AML/CFT Law.
- Maintain a register of submitted SARs/STRs and confirmations received from regulators.
5. AFSA AML Return and Regulatory Reporting
- Prepare and submit the annual AML Return Form to AFSA.
- Notify AFSA of any significant AML breaches, audit findings, changes in the AML Framework, or the appointment of a new MLRO.
- Manage all correspondence and engagement with AFSA and FIU on AML/CFT matters.
6. AML Risk Assessment
- Develop and maintain the company-wide Money Laundering and Terrorist Financing Risk Assessment (ML/TF Risk Assessment).
- Identify and assess risks across customers, products, delivery channels, and jurisdictions.
- Update Customer Risk Assessments and Business Risk Assessments at least annually.
7. Independent Audit and Testing
- Organize independent testing or audit (internal or external) of the AML/CFT program.
- Oversee the implementation of corrective measures based on audit findings.
8. Training and Awareness
- Conduct regular (at least annual) AML/CFT training sessions for all employees and management.
- Develop training materials, maintain training records, and conduct knowledge assessments.
- Ensure staff awareness of new money laundering typologies and changes in AML/CFT legislation.
9. Record-Keeping
- Maintain all AML-related documentation (CDD/EDD files, reports, regulatory correspondence) for a minimum of five years.
- Ensure secure and accessible storage of records for AFSA/FIU inspections.
10. Communication and External Relations
- Represent the company in interactions with AFSA, FIU, law enforcement, and other competent authorities.
- Handle official requests and correspondence from regulators and ensure timely, accurate responses.
- Maintain professional relationships with external auditors, consultants, and regulatory bodies.
Candidate Requirements
Education
- Bachelor’s or Master’s degree in Law, Economics, Finance, or Business Administration.
Experience and Qualifications
- Minimum 2–3 years of professional experience in AML/CFT, financial monitoring, or compliance.
- Strong knowledge of AIFC AML Rules, AFSA Guidance, Kazakhstan AML/CFT Law, and FATF Standards.
- Professional AML certification (CAMS, ICA, or ACAMS) is mandatory or strongly preferred.
Personal Attributes
- Strong analytical and investigative skills, attention to detail, honesty, and independence.
- Excellent command of English and Russian (oral and written).
- High level of integrity and ability to handle confidential information.